Mandatory E-Invoicing in the EU: In Which Countries Does This Apply?

30.03.2020

Topic: E-Invoicing | Digitalization

Last update: May, 2nd 2022

According to EU Directive 2014/55/EU, all public contracting authorities and entities must be able to receive and process electronic invoices. But in transposing this directive into national law, many EU states have gone one step further, introducing mandatory e-invoicing for suppliers and contractors. This means that all invoices sent to public contracting authorities must be electronic, and that invoices in paper form will no longer be accepted. Some countries, e.g. Italy and France, have gone so far as to impose mandatory e-invoicing for all domestic invoices, including those sent to companies and private citizens.

This blog article provides an overview of the current situation (i.e. in May 2022) in certain EU Member States* and answers the following crucial question: As a vendor, are you required to send e-invoices? And if so, what format should these e-invoices be in, what are the deadlines, and are there any other important points to consider?

Austria

Yes, e-invoicing has been mandatory for all B2G invoices since January 1, 2014. Invoices must be sent via www.e-rechnung.gv.at. Current versions of the ebInterface and PEPPOL-UBL formats are supported.

Belgium

Yes and no. Authorities in the Flemish region have not accepted paper invoices since 2018. In the rest of the country, mandatory e-invoicing only applies to contracts above EUR 135,000. The portal “Mercurius” (https://digital.belgium.be/e-invoicing/MercuriusLogin.html) can be used to submit e-invoices.

Croatia

Yes, e-invoicing has been mandatory for all B2G invoices since July 1, 2019. Invoices must be based on the Oasis UBL 2.1 format. The platform to be used is called Servis eRačun za državu.

Czech Repuplic

No, public bodies must be able to accept e-invoices but sending e-invoices is not mandatory. The deadlines for being able to accept e-invoices were April 1, 2019 and April 1, 2020.

Cyprus

No, but mandatory invoicing is being discussed as the country implements EU Directive 2014/55/EU.

France

In the future, yes. France has announced the introduction of mandatory e-invoicing, for the purpose of tax reporting, for companies. The deadlines are staggered by company size and will take effect between July 2024 (for large companies) and January 2026 (for all companies).

Germany

Yes and no: Due to Germany’s federal structure, regulations vary. E-invoicing is mandatory for public contracting authorities and entities of the federal government and the state of Bremen by November 2020. Baden-Württemberg, Hamburg and Saarland followed in the beginning of 2022. Mecklenburg-Vorpommern follows in April 2023, Rheinland-Pfalz and Hessen announced an obligation starting 2024. In the other German states, e-invoicing has not been made mandatory or else a decision has not yet been made. The preferred format for invoices in Germany is XRechnung.

Greece

No, e-invoicing is not mandatory, but there are plans to introduce mandatory e-bookkeeping.

Hungary

No, but Hungarian companies are required to send B2B invoices for amounts exceeding HUF 100,000 (approx. EUR 300) to the responsible tax authority within 24 hours using the NAV (Nemzeti Adó- és Vámhivatal) system. The value limit has been removed in 2021, so all B2B and B2C transcations are now affected.

Ireland

No, public bodies must be able to accept e-invoices, but it is not mandatory to send e-invoices. The deadlines were April 18, 2019 and April 2020.

Italy

Yes, e-invoicing has been mandatory for B2G since 2015. On January 1, 2019, this requirement was expanded to domestic B2B and B2C invoices in Italy. Invoices must be in an XML format called FatturaPA and sent via a hub called SdI (Sistema di Interscambio).

Lithuania

Yes, since July 2017, e-invoicing is mandatory for B2G, it must be transmitted via the portal eSaskaita.

The Netherlands

Yes, e-invoicing has been mandatory since January 1, 2017 for all invoices sent to the central government. Invoices must be in UBL-OHNL format. The e-invoicing requirement was expanded and has applied to invoices sent to all public contracting authorities since April 18, 2019.

Poland

Yes, as of January 2022, the exchange of e-invoices via a state portal (Krajowy System e-Faktur, KSeF for short) will be possible in Poland. After a one-year test phase, use of the system is to become mandatory in 2024.

Portugal

Yes. The obligation to send e-invoices to contracting authorities was originally scheduled to take effect as early as April 2020 for large companies and December 2020 for small companies. Due to the Corona pandemic, these deadlines have been extended to December 2020 for large companies, June 2021 for mid-size corporations and December 2021 for small enterprises.

Romania

Partly. Contracting authorities must accept e-invoices (format: e-Factura RO), but contractors are not obliged to send them. From July 2022, an e-invoicing obligation will take effect for certain product groups that are particularly vulnerable to tax evasion, including fruit and vegetables, alcohol, clothing and construction.

Serbia

Yes. As of January, 1st 2022, sending e-invoices to public sector customers is mandatory. In B2B, the obligation is becoming effective from January 2023.

Slovakia

Yes. Since January 2022, e-invoices to contracting authorities (sent via IS EFA) are mandatory. The obligation for B2B invoices will follow in January 2023.

Spain

Yes, e-invoicing has been mandatory for B2G invoices since 2015. The required format is called FacturaE. The gradual introduction of an e-invoicing obligation in B2B is also planned; the exact deadlines have not yet been set.

Sweden

Yes, e-invoicing has been mandatory for B2G invoices since April 2019. Invoices must be sent via SFTI (Single Face to Industry).

*Unfortunately, up-to-date information was not available on every EU Member State. No liability is assumed for the accuracy and completeness of the information provided in this blog article.